Consumer Duty
What it means for us, our customers and distribution partners
We recognise that all of our customers are individuals with different needs, some of whom need additional care, and we’re committed to supporting the fair treatment of vulnerable customers.
Since the publication of the FCA’s guidance on the fair treatment of vulnerable customers, we have been delivering a number of improvements to reach a higher standard of care, such as:
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Our Customer Strategy is helping us gain a better understanding of the needs of our target market and customer base, through detailed customer segmentation, which includes consideration of existing and potential vulnerabilities
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Internally, we have launched a new annual mandatory vulnerable customer awareness training module for all employees alongside more in-depth training on key vulnerability support topics such as resilience, bereavement, dementia awareness, communication, financial vulnerability, and suicide
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A new customer vulnerability champion community has been formed to offer guidance and support to colleagues across the business alongside a vulnerable customer support hub – which hosts key processes, tools and guidance that our employees have access to. Where our employees may need additional support, a vulnerable customer referral group can convene at short notice to provide guidance and make decisions outside of our normal processes
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Our Conduct Risk Operating Policy and Standard set out the requirements for identifying and responding to customer vulnerability, which are incorporated into supporting processes and procedures across the product lifecycle (e.g. product design, service provision and communications). In addition, we have enhanced our product lifecycle management framework to include a focus on vulnerability and developed a vulnerable customer risk assessment framework
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Our design principles, brand guidelines and tone of voice guidelines are regularly reviewed to consider vulnerable customers, alongside an accessibility review of our website. We have also standardised and simplified our process for customers requesting information in alternative formats
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We use the results from call monitoring and complaints to assess whether we’re meeting the needs of our customers. We have also enhanced our current quality assurance frameworks to specifically reference the identification and handling of vulnerability – and implemented improvements where needed. Customer vulnerability case studies are regularly discussed within our customer experience and complaints forums, with improvement actions agreed
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We’re investigating how our systems can capture who our vulnerable customers are, through an ‘Additional Care’ marker alongside details of the vulnerability characteristic and support requirements. We’re also building a suite of vulnerability scorecards to allow us to understand how we’re performing for vulnerable customers and those needing additional care
How we help customers in need of more support
We can provide customers with documents in alternative formats, such as braille, large print, or an audio file. If they have difficulties communicating over the phone, they are able to contact us via Relay UK by using the Relay app or dialling 18001 before our phone number.